Personal Information Protection

Private Sector Privacy Legislation

Personal Information Protection Policy

 

The Gold Room Jewellers

 Personal Information Protection Policy

 

At The Gold Room Jewellers, we are committed to providing our clients / customers with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information regarding our clients / customers, protecting their personal information is of high priority.

 

While we have always respected our clients / customers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, and sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

 

We will inform our clients / customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

 

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ / customers’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ / customers’ personal information and allowing our clients’ / customers’ to request access to, and correction of, their personal information.

 

Definitions

 

Personal Information – means information about an identifiable individual  E.g., including name, age, home address, phone number, email address and marital status.  Personal information does not include contact information (described below).

 

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.

 

Privacy Officer – means the individual designated responsibility for ensuring that Douglas Davey complies with this policy and PIPA.

 

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the client / customer, member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will only collect client / customer information that is necessary to fulfill the following purposes:

 

• To verify identity;

• To identify [client / customer] preferences;

• To deliver requested products and services

• To enroll the client in a program;

• To ensure a high standard of service to our [clients / customers];

• To meet regulatory requirements;

• To announce special events and promotions to our [clients / customers];

• To celebrate our [clients / customers] special occasions, such as birthdays and anniversaries

 

Policy 2 – Consent

2.1  We will obtain clients’ / customers’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided orally, in writing, electronically or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client / customer voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a client / customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client / customer does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), client / customer can withhold or withdraw their consent for The Gold Room Jewellers to use their personal information in certain ways.  A client’s / customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the client / customer in making the decision.

2.5 We may collect, use or disclose personal information without the client’s / customer;s knowledge or consent in the following limited circumstances:

 

• When the collection, use or disclosure of personal information is permitted or required by law;

• In an emergency that threatens an individual's life, health, or personal security;

• When the personal information is available from a public source (e.g., a telephone directory);

• When we require legal advice from a lawyer;

• For the purposes of collecting a debt;

• To protect ourselves from fraud;

• To investigate an anticipated breach of an agreement or a contravention of law

 

Policy 3 – Using and Disclosing Personal Information

3.1  We will only use or disclose client / customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

 

• To conduct client / customer surveys in order to enhance the provision of our services;

• To contact our clients / customers directly about products and services that may be of interest;

3.2  We will not use or disclose client, customer personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell client / customer lists or personal information to other parties [unless we have explicit consent to do so].

 

Policy 4 – Retaining Personal Information

4.1  If we use client / customer personal information to make a decision that directly affects the client / customer we will retain that personal information for at least one year so that the client / customer has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain client / customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

 

Policy 5 – Ensuring Accuracy of Personal Information

5.1  We will make reasonable efforts to ensure that client / customer personal information is accurate and complete where it may be used to make a decision about the client / customer or disclosed to another organization.

5.2  Clients / customers may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If  the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note the clients’ / customers’ correction request in the file.

 

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of client / customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  The following security measures will be followed to ensure that client / customer personal information is appropriately protected:

• The use of industry approved safes for storage as appropriate

• The use of password protected and encrypted off-site back-up data storage

• The use of password secured on-site computer systems

• The use of industry approved physical site security (locks, alarms and video)

6.3  We will use appropriate security measures when destroying client / customer personal information such as:

• Cross-shredding client / customer data if in paper format

• Electronically deleting data that has been requested to be deleted by client / customer or is no longer required for the proper operation of the business or support of the client / customer.

6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

 

Policy 7 – Providing Clients / Customers Access to Personal Information

 7.1  Clients / customers have a right to access their personal information, subject to limited exceptions:

• Solicitor client privilege, where disclosure would reveal personal information about another individual health, safety or financial well being.

• Court ordered cease and desist, where there is a legal requirement for The Gold Room to withhold access from the client / customer to their Personal Information on file.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3  Upon request, we will also tell client / customer how we use their personal information and to whom it has been disclosed if applicable.

7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5  A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client / customer of the cost and request further direction from the client / customer on whether or not we should proceed with the request.

7.6  If a request is refused in full or in part, we will notify the client / customer in writing, providing the reasons for refusal and the recourse available to the client / customer.

 

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or a designated alternate individual is responsible for ensuring The Gold Room Jewellers compliance with this policy and the Personal Information Protection Act.

8.2 Clients / customers should direct any complaints, concerns or questions regarding The Gold Room Jewellers compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client / customer may also write to the Information and Privacy Commissioner of British Columbia.

 

Contact information for The Gold Room Jewellers’ Privacy Officer:

Douglas (Doug) Davey

12014 72nd Avenue

Surrey, BC, V3S 3V1

604-590-5199